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Importing food to Canada: a step-by-step guide

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

Introduction

This guide describes the recommended steps you can follow to meet the requirements to import food into Canada and to maintain a food import licence. As an importer, it's your responsibility to make sure the food you import is safe and that it meets Canadian requirements.

For additional information refer to the frequently asked questions on importing food.

Before you import

Step 1: Know your food – what are the risks?

Are you knowledgeable about the food that you are importing? Importing safe food starts with having a good understanding of the food you import.

This includes knowing the following:

can you describe the food you import? (this includes the type of food, its common name, the quantity you intend to import, the packaging of the food)

have you identified the hazards reasonably expected to occur with the food you are importing? These hazards must be prevented from occurring, or they must be eliminated or reduced to a level that does not pose a risk to human health

do you have a general understanding of the supply chain(s) for the foods you are importing? Consider the following:

is the food sent to Canada directly from the manufacturer

is it subject to another process such as being packaged, processed or labelled by another company and/or in another country before it arrives in Canada

in general, the more complex the supply chain, the more opportunity there is for a hazard to occur. Understanding the supply chain for your foods is important because it helps you identify and address hazards

You are encouraged to work with your foreign supplier to ensure each of these:

you understand the supply chain for your food

you understand how the foreign supplier is addressing all hazards associated with the food

you know if the food will need further processing or labelling after it arrives in Canada, so it will meet Canadian requirements

you can demonstrate that the food is manufactured, prepared, stored, packaged and labelled under conditions that provide at least the same level of protection as provided by the SFCR

Keep in mind

Under the SFCR, the supply chain may extend beyond the person who provided you the food before it came to Canada. The supply chain includes anyone who manufactures, prepares, stores, packages or labels the food before it comes to Canada.

Having a good understanding of the food you import will give you a strong foundation for developing your written preventive control plan (PCP). It will also provide you with confidence that your import process is effective at importing safe food that meets Canadian requirements.

Did you know?

Step 2: Familiarize yourself with Canadian requirements for importing food

As an importer, you should consider the following three categories of requirements related to food imports.

1. Food requirements

The food you import is required to meet general food safety requirements such as having been manufactured, prepared, stored, packaged and labelled under sanitary conditions. This requirement is met by meeting the requirements of section 11 as described in more detail under Step 3.

In addition to the food safety requirements for imported food, you are required to become familiar with any applicable requirements related to standards, grades, net quantity and labelling. More information can be found in the Industry Labelling Tool and the Food safety standards and guidelines.

Step 3: Select an appropriate foreign supplier

Under the SFCR, you are responsible for ensuring that your foreign supplier is manufacturing, preparing, storing, packaging or labelling the food before it is imported into Canada under the same conditions required in Canada. Your foreign supplier(s) needs to be aware of Canadian food safety requirements and be willing and able to provide you with the information you need to demonstrate food safety controls are in place. See Types of foreign suppliers below for more information in this.

In general, for all food except meat and shellfish, the SFCR does not restrict import from certain countries or suppliers. See the Automated Import Reference System (AIRS) for up-to-date information on any additional import restrictions related to food.

The type of information you need from your foreign supplier will vary. It will depend on

the food being imported

the types of activities or processes the food is subject to before being imported and

whether there are existing oversight measures in place that the foreign supplier is subject to

Types of foreign suppliers

The type of foreign supplier you are sourcing your food from will affect the documentation you need to include in your PCP to demonstrate that you meet the foreign supplier requirements of the SFCR.

1. Importing food from a foreign supplier in a country that the CFIA has entered into a recognition arrangement with, and the food being imported is part of this arrangement

There are 3 types of recognition under CFIA's Foreign Food Safety Systems Recognition Framework. These are:

foreign food safety systems recognition

commodity specific recognition

recognition of systems of inspection as a pre-requisite to trade

In general, the above recognition arrangements mean that we have assessed the food safety system in the foreign country and determined that it provides a similar level of food safety control as that provided by Canada's food safety system.

The following are minimum documentation requirements when importing food from a foreign supplier in the US under the Foreign Food Safety Systems Recognition Arrangement with the US; or when importing meat or shellfish from a foreign supplier in a country with an approved inspection system and from an approved establishment. In all cases the food being imported must be subject to the recognition arrangement.

confirm and keep documented evidence that the food to be imported is part of the arrangement; and

confirm and keep documented evidence that the foreign supplier(s) is subject to the oversight of the foreign government and is in good standing within the recognized system

for example, the foreign supplier is not subject to an enforcement action in the foreign country

foreign supplier means any person or company that is manufacturing, preparing, storing, packaging or labelling the food in the foreign country

For meat products and shellfish, you should regularly consult Importing from specific countries to confirm that there has been no change in the status of a foreign countries' approved food safety system or the establishments operating under it. You should keep a record of this verification activity.

2. Importing food from a foreign supplier that is part of an internationally recognized third-party certification program, and the food to be imported is subject to this program

As a food importer, you may choose to source food from a foreign supplier who is certified to an internationally recognized food safety certification program. In doing so, you must do the following:

If you identify any preventive controls that are not addressed by the food safety program, you may need to obtain additional documentation from your foreign supplier describing how these are being addressed.

confirm and keep documented evidence that the foreign supplier is in good standing with the certification program

This may be written evidence of the results of their most recent audit and/or other evidence that they are meeting the criteria of the program certified by the third-party competent authority that conducts the audit function.

3. Importing food from a foreign supplier that is not subject to the oversight described above

You may choose to source food from a foreign supplier who is not subject to oversight from a competent authority that is part of a food safety system recognition arrangement with the CFIA or that is not part of a third-party food safety certification program. This would include suppliers subject to private, company specific auditing programs or certification standards.
In this case, for each type of food you import your foreign supplier assurances should include:

A review of Regulatory requirements: Preventive controls to identify each of the controls that apply to the food you intend to import. The relevant preventive controls will be dependent on the type of food, the activities conducted by the foreign supplier in producing the food and the types of hazards that are most likely to occur in the food

Once the relevant preventive controls have been identified, you need written confirmation that these controls are being implemented effectively. The SFCR does not specify how you must confirm this. However appropriate actions may include:

on-site foreign supplier visits to observe effectiveness of controls

These visits could be conducted by you, the importer, or by a third party acting on your behalf.

In all cases, you should ensure that the onsite assessment is conducted by a technically competent person with the knowledge and expertise to assess the relevant preventive controls are being effectively implemented; and/or

obtaining written documentation from the foreign supplier that demonstrates that all of the relevant control measures are being implemented effectively. At a minimum, this includes:

the name, address and contact information of the process authority or technically competent person who developed the process and implements the preventive controls

a product and process description that includes technical information demonstrating that the product was adequately processed and that the preventive controls were adequately implemented to address the hazards most likely to occur in the food and

a written statement signed by the process authority or technically competent person attesting that the described process will produce a food that meets Canadian requirements

Step 4: Preventive control plan – create it and implement it

A PCP is a written document that outlines the measures and controls taken to ensure the food you are importing is safe and fit for human consumption and complies with Canadian requirements.

Note that if you conduct other food-related activities other than importing (such as manufacturing, preparing, packaging or labelling food in Canada that will be exported or sent between provinces), your licence and PCP may have to cover these activities as well.

Step 5: Develop a complaints and recall procedure

Before applying for your import licence, you must develop your complaints and recall procedure

Complaints procedure

Written procedures to show how you receive, investigate and respond to complaints will help you handle them in a timely and consistent manner.

A complaint received on a product could be an important indicator of a possible issue with food safety controls applied by the foreign supplier and/or problems arising during distribution and handling of the food.

If a consumer complaint or other finding (for example, company testing) results in a recall, you must be prepared to quickly recall all affected product from the marketplace. If the food subject to the recall represents a risk to the health of Canadians, you are required to notify us of this issue immediately.

To prepare for a potential recall, you are required to create a written recall procedure that

describes how the recall will be conducted and the name of the person who is responsible for maintaining the procedure, and

Step 6: Apply to the CFIA for your licence to import

A licence is required to import food (including food ingredients) into Canada.

You are required to provide this import licence number, along with all other pertinent information about the shipment described under Step 7, to CBSA and CFIA, for each shipment you intend to import.

To obtain an import licence, you need to sign up with My CFIA. By signing up with My CFIA, you can create one or more business profiles based on an enrolment model that suits your business. You can apply for your licence online or access information about the licence and regulations ‎through your My CFIA account.

Your licence is valid for a period of 2 years from the effective date indicated on it. As your licence approaches expiry, you can apply to renew your license.

For more information about licensing requirements or My CFIA refer to Licensing or My CFIA.

When it's time to import

Once steps 1 to 6 are complete, you are ready to start importing.

Step 7: Provide the CFIA with information about each of your shipments

The CBSA and the CFIA need to be notified of all food shipments imported into Canada that are destined for sale to Canadians.

As part of the import process referenced above, the SFCR require you to provide certain information about all food shipments that you import prior to or at time of importation. You can find import information in Regulatory requirements: Trade.

You are responsible for consulting AIRS regularly to ensure you or your broker provides the CFIA with all the required information and documentation required for release of the shipment into Canadian commerce.

After you've imported

Step 8: Keep traceability records

You are required to keep traceability records for all the foods you import. The documents must allow you to trace your imported food forward to the immediate customer and back to the immediate supplier.

Tracing the imported food back to the immediate supplier means you need to keep a record of the name and address of the person or food business that sold or consigned the imported food to you (for example, the vendor). You also need to document the date the food was sold or consigned to you.

Tracing the food forward to the immediate customer means you need to keep a record of the name and address of the person to whom you transferred care, control, ownership and/or responsibility of the food after it was imported and the address of that person or food business. If you are selling your imported food at your own store; you are not be required to keep a record of your customers who has purchased the imported food.

Your records need to be clear, readable and accessible in Canada for two years. They must also be provided to the CFIA upon request and must be in English or in French. If you use electronic records, they need to be provided in a format that can be easily read by standard computer software.

Step 9: Preventive control plan – maintain it

You should consider your PCP to be a "living document," meaning that as things change in your import operation; your PCP gets updated to reflect those changes.

Your PCP should be reassessed and updated at regularly to ensure that it is current and working effectively.

You should also update it when a change occurs, such as a change in your supplier or a change in food safety controls applied by your supplier.

You should consider a review of your PCP when a potential problem is identified, such as a complaint or a recall related to a food you imported.

You are required to keep the documents that you receive from your supplier that demonstrates the effectiveness of your PCP. You need to keep these for 2 years after the day on which it is prepared.

Step 10: Implement the complaints and recall procedure as required

You are required to keep a record of any complaints you receive regarding the foods you import in accordance with the procedure you developed under Step 5.

When you receive a complaint, you are required to keep a record of the complaint and determine whether the food in the complaint represents a risk to the health of Canadians and if the requirements of the SFCR are not being met.

If you determine this is the case, you are required to notify the CFIA of this issue.

Your complaints procedure needs to outline how these steps will be carried out.

You are required to implement your complaints procedure, as needed, by taking action to follow up on a complaint and keeping a record of the details of these follow-up actions.

You are required to keep any documents related to a complaint you received and the actions taken. You need to keep these for 2 years from the date the follow-up actions were completed.

Implementation of your recall procedure includes taking actions to remove the food that is subject to the recall from the marketplace and, if the food presents a risk to human health, notifying the CFIA immediately. You need to write down all details of a recall and need to keep these for 2 years after the day the recall was started.

To ensure your recall plan will be effective, once every 12 months you are required to simulate a recall using your written procedure. You need to write down details of the recall simulation and the results and you need to keep these for 2 years from the day the recall simulation ended.

Global Affairs Canada (GAC)
The Trade Controls Bureau of GAC is responsible for issuing import permits for goods on the Import Control List under the authority of the Export and Import Permits Act.
For more information on agricultural products that are subject to import controls see the Controlled products web page.

Provincial, territorial and municipal governments
Provincial, territorial and municipal programs focus on the food service industry (including restaurants and caterers), and the food retail industry. However, some provinces and territories have additional requirements for certain commodities.

For more information regarding provincial, territorial and municipal food safety systems and associated requirements, visit the website for the province, territory or municipality in your area. Here is a list of the various provincial and territorial ministries.

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